Tax Law News and Insights

New tax law contains some pitfalls that should require switching your tax regimen. The Tax Cuts and Jobs Act of 2017 contains an amazing new provision of the Internal Revenue Code called Section 199A. Section 199A provides tens of millions of owners of pass-through businesses, including at least 5 million...

Read More

On August 1, 2018, the I.R.S. issued 145 pages of proposed regulations (REG-104226-18) relating to the Code §965 Transition Tax applicable to the 2017 taxable year of U.S. Shareholders holding interests in a deferred foreign income corporation ("D.F.I.C."). A D.F.I.C. is any specified foreign corporation of a U.S. Shareholder that...

Read More

As we noted previously, the IRS announced in March that it will end its Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. Under OVDP, a taxpayer with undisclosed foreign assets or income could come forward to pay tax, interest and reduced penalties in exchange for immunity from criminal prosecution....

Read More